Advanced Shoreline Permitting: No Net Loss and Mitigation

The Shoreline Management Act and all comprehensively updated Shoreline Master Programs (SMP) require that authorized activities result in no net loss (NNL) of shoreline ecological functions. Although NNL is a fundamental regulatory concept that underpins many SMP policies and regulations, little implementation guidance exists in this area.

In this new chapter of the Shoreline Permitting Manual, we consider how to review individual shoreline proposals for the careful and complete implementation of SMP NNL requirements. Ecology developed this guidance for local government practitioners who review shoreline proposals. Content covers:

• Mitigation sequencing as the mechanism for achieving NNL,
• How applicants should document mitigation sequencing,
• The use of project scenarios to reinforce concepts and best practices,
• Practical guidance on reviewing mitigation plans, and
• Tools and resources for improving compliance with mitigation sequencing and NNL requirements.

This chapter will help local practitioners to communicate requirements to applicants, identify deficiencies in site-specific documentation, and carefully and completely evaluate proposals for correct mitigation sequencing.

The scope of this guidance is limited. This chapter does not present a standard methodology for assessing shoreline functions, and it does not present prescriptive mitigation guidance (5 AICP credits/CEP Points).

Misty Blair is the statewide Shoreline Management Policy Lead with the Washington State Department of Ecology. The Shoreline Management Policy Lead deals with complex shoreline management issues; researching, developing and implementing new shoreline planning policies, procedures and initiatives; coordinating shoreline planning and permitting activities to ensure statewide consistency; and providing technical support and guidance to SEA program planning staff statewide. Misty has been with Ecology for 9 years and previously worked in environmental planning/permitting for the City of Tacoma. She has a BS in environmental policy and land management from the University of California, Berkeley (2002).

Carolyn Chase is the Shoreline Management Compliance Lead with the Washington State Department of Ecology. Her work focuses on developing strategies and processes for understanding how effectively Shoreline Master Programs are being implemented across the state and supporting efforts to address noncompliance. Previously, Carolyn has worked as a land use planner, environmental planner, and transit planner. She graduated from the University of Pennsylvania with a Master of City and Regional Planning degree and holds a B.S. in Environmental Science from Western Washington University. Carolyn has been with Ecology for three years and is an AICP certified planner.

Rebecca Rothwell is a Shoreline Planner with Ecology’s headquarters office and represents the SEA Program in the development and review of statewide guidelines, policies, and regulations related to protecting and managing the state’s shorelines. She has 11 years’ experience with reviewing shoreline permits, providing technical assistance to applicants and consultants, and coordinating with property owners to resolve SMA violations. Rebecca has a bachelor’s degree in biology from the University of Puget Sound and a master’s degree in environmental studies from The Evergreen State College. She has worked at Ecology for 15 years.